The DFO Science Advisory Process used to
generate advice for the new Atlantic Seal Management Plan included no
consultation on ecosystem considerations: This is a serious omission that
requires urgent correction.

Dear Mr. Regan,

Please elicit advice from DFO Science on how
ecosystem considerations should be incorporated into the next Atlantic Seal
Management Plan. At this time, the Science Advisory Schedule does not
indicate that any meeting has been held, or is planned, with the objective of
producing advice on this matter. Omitting ecosystem considerations from marine
resource harvest planning should no longer be acceptable practice in Canada.

DFO held a Science Advisory meeting on September 7
– 8, 2005 to discuss “Harp and Grey Seal: science advice for the next Atlantic
Seal Management Plan.” I was not permitted to participate in this meeting. This
meeting failed to meet DFO’s criteria for transparency and inclusiveness, and
insufficient information was considered.

On October 17, 2005 the Terms of Reference for the
above mentioned science advisory meeting were made public on DFO’s website. The
Terms of Reference indicate that discussion was limited to modeling trends in
seal populations under various harvest management scenarios, with a view to
recommending quotas for future seal hunts. Also discussed was the updated size
estimate for the Scotian Shelf grey seal population, and a “Potential Biological
Removal” (PBR) was calculated on this basis.

I am greatly concerned to note that the list of
working papers and background documents that were considered by the meeting
participants lacked any publication describing ecosystem considerations in
marine resource management. Participation in the meeting was limited to three
DFO scientists who have worked on seal biology and seal population models, and
two external participants with similar backgrounds, both of whom were previously
appointed to the “Eminent Panel on Seal Management” in 2000-2001.

There is no sign that the creation of science
advice for the new seal management plan was done with any consideration of the
gains in ecosystem understanding that have been made by DFO Science in the years
since the Eminent Panel completed its investigation. But this is clearly what
should have been done under Canada’s Oceans Strategy (2002), which includes
“ecosystem-based management” as a major tenet. The report of the Eminent Panel
(2001), and seal hunts subsequently planned on its basis, did not include
ecosystem considerations. It is important to realize that much has changed since
2001, and a reiteration of the conclusions of the Eminent Panel on Seal
Management neither meets current “ecosystem-based” management criteria, nor does
it compare to the best science now available from DFO.

Since 2001, DFO has made much progress towards its
goal of broadening the scope of marine resource management from single-species
models to holistic “ecosystem management.” It is now widely recognized by
scientists that a single species approach to management risks causing
broad-scale unintended consequences at the ecosystem level. A great deal of
scientific thought in the last few years has been devoted to finding ways to
understand, to avoid and to mitigate such ecosystem damage.

Since 2001, DFO scientists have published
ground-breaking analytical ecosystem studies. Exhaustive reviews have been
completed as DFO scientists have tried to integrate their knowledge of a great
many ecosystem components and their complex patterns of interaction. Masses of
oceanographic data have been analyzed in new ways, and new patterns have been
discovered. DFO’s first “Ecosystem Status Reports” and “Habitat Status Reports”
were produced in 2003. Comprehensive ecosystem studies have also been done under
CDEENA, and new hypotheses have been advanced by DFO scientists to explain
unexpected changes in marine food webs. Also, DFO’s open collaborative approach
to planning for integrated management of multiple ocean uses seems now to be
progressing nicely.

Mr. Regan, it is unacceptable to think that you
may not be given the benefit of this body of new knowledge in science advice on
seal management provided to you this fall. Missing may be important insights
into ecosystem science that were recently gained by DFO, concepts that must now
be considered when setting objectives for the management of the seal herds.
However, it seems that if you wish to receive this level of current,
comprehensive science advice on this matter, you must ask for it explicitly.

Please act without delay to trigger a DFO
science advisory meeting tasked with providing your office with objective
science advice on how ecosystem considerations should be applied to seal
management. Please also ensure that this additional
science advice on seal management is delivered to your office prior to your
approval of the next Atlantic Seal Management Plan. I would appreciate an
opportunity to provide input in drafting the Terms of Reference for this
proposed meeting, and I would also appreciate being invited to attend the
meeting as an external participant. Thank you.

Sincerely,

Debbie MacKenzie

P.S. Below is a list of some recent publications
written by DFO scientists, that contain information relevant to the task of
including ecosystem considerations in planning seal herd management. I recommend
inviting several of these authors to the proposed advisory meeting (at least
Rice, Frank and Bundy), along with the DFO seal biologists who took part in the
science advisory meeting that was held on September 7 – 8, 2005.